Compliance Policy

PRODOIST SOLUTIONS. since its foundation has always sought development in order to provide employees, customers, suppliers and society in general a relationship society in general a relationship supported by ethical conduct and socially recognized principles.

The high standards followed by PRODOIST, both past and present, are key factors in our growth.

The Code of Conduct already establishes that PRODOIST cohibits any concession of advantage or privilege to public agents, ensuring compliance with the policies, norms and controls of prevention and combat of money laundering and illicit acts of any nature, in strict compliance with the applicable laws and the best national and international practices.

Therefore, our Compliance Policy is a set of disciplines that define the way of doing business that must be followed by the professionals who work for PRODOIST.

Failure to comply with our policy may lead to termination of the person's relationship with PRODOIST.

PRODOIST and its employees are committed to conducting business in a legal, ethical, transparent and professional manner. Therefore, this is the conduct that the company must adopt during the conduct of business and before the anti-corruption laws.

This Manual aims to ensure that employees and representatives of PRODOIST understand the general requirements of anti-corruption laws, in particular the Foreign Corrupt Practices Act Corrupt Practices Act (FCPA - Foreign Corrupt Practices Act) and the Federal Law 12.846/2013, also serving as a prevention tool to guide employees to recognize and employees to recognize and avoid conflicts and violations of these laws.

For the purposes of this Manual, PRODOIST considers the anti-corruption laws to apply to all employees, including Board members and Directors, and any acting on behalf of the company.

All third parties representing PRODOIST, such as consultants, service providers, business partners, suppliers, etc., will be informed of this manual and will undertake to follow all pertinent anti-corruption laws, as a prerequisite for acting on behalf of PRODOIST.

After reading this Manual, the employee must complete and sign the Term of Commitment, as proof that the message has been understood and will be followed.

The employee who has any doubt or question about this Manual, any law or anti-corruption regulation, must ask for clarification from his or her immediate manager or, if necessary, seek support from the Legal area.

All employees must conduct business on behalf of PRODOIST in a transparent manner with the customer.

The information and conditions that involve the sale must be given to the client, who will then formalize his acceptance through the signature of legally authorized persons either to:

• Delivery of objects or services;
• Negotiating discounts or differentiated conditions for the customer;
• Formalization of Contract;
• Formalizing any necessary or complementary changes.

The employee must keep records that accurately and fairly reflect its transactions, and establish accounting controls to provide reasonable assurance that transactions are recorded transparently and accurately to the customer.

These requirements have the objective of avoiding undue expectations from the client as to the contracted object, affecting the perception of quality of PRODOIST in the market, and, therefore, the collaborators must

• Actively participate in training sessions to learn about our solutions;
• To fully understand the customer's demand;
• Validate with the customer your understanding;
• Present the solution you will offer to the customer with propriety, without subterfuge or incorrect information.

All employees and third parties acting on behalf of PRODOIST must fully comply with this manual. Therefore, employees of PRODOIST and third parties acting on its behalf are prohibited from offering, promising, making, authorizing, or providing (directly or indirectly, including through third parties) any improper advantage, payments, gifts, or the transfer of anything of value to any public or private official (including their family members), to influence or reward any official action or decision by such person for the benefit of the company or oneself.

Any promise must go through formal internal and/or manufacturer approvals, ensuring that the contracted content will actually be delivered as contracted.

Informal sales are forbidden: with conditions or items that are not explicit in the signed contract and/or without the proper internal approval process.

Recommendations:

• Prior identification of customer requirements;
• Previously formalized internal and/or manufacturers' approvals;
• Explicit formalization in a contract of everything required;
• Checking of all documents and validation of all information.

It will only be authorized the formalization of a sale, when the documents that make up the contracting process by the customer are checked and attached to our system and yet, the signature of these documents is made by a duly authorized person.

The employee who works in the sales area must be sure about all the necessary documents so that PRODOIST is contracted and able to make the resulting invoices. and must be convinced about who should be the person responsible for signing the documents;

Manipulation of sales closing from non-valid documents or responsible parties will not be accepted by PRODOIST.

Recommendations:

• Checking the customer's budget(s) before the sales process generates proposal;
• Identification of all the documents that the customer has in his process to formalize a hiring/authorize billing;
• Identification of who is responsible for the signatures on each document;
• Checking that all documents are properly signed before the sale is formalized;
• Checking the powers of those in charge.

Every price proposal can only be presented to the customer if properly issued via the system, to ensure that the conditions have been given and approved properly. Discounts given by the manufacturer can only be considered if formally received and attached to the system.

Manufacturers' price levels may only be used from the table if validated internally with the responsible parties. Adhesions can only be accepted if the proposal is submitted is submitted via the system and the costs have made it feasible.

• No price, tax composition, or discount may be offered to the customer without prior formal authorization received from the manufacturer or the responsible area;
• No adhesion to the Price Register can be formalized or committed without the previous validation of the costs that will make the sale possible;
• The choice of list price level should be confirmed with those responsible in the area of manufacturers;
• The customer data must be correct so as not to generate undue prices;
• The budget information must be consistent with the groups in the proposal.

During a price negotiation, the sales professional may only negotiate within the range that he or she is authorized, neither under nor over, unless he or she has submitted for management approval.

In this way, PRODOIST will be protected and the customer will be receiving a fair price. The conditions given to the customer are confidential and may not be used for any other purpose, except for dealing with the client.

Recommendations:

• It always issues proposals via the system, which has the cost prices suitable to the customer and predefined sales limits;
• Validate with the responsible area the practiced taxes, especially when the price has a hardware composition;
• Bank financing, dealer installment plan, or HAAS or SAAS model must be validated by the Commercial Director or the managing partners in the operation;
• Prior information of the discount percentage by attaching your formal authorization in the System;
• Prior validation with the customer before issuing a proposal regarding his budget and his billing data, because these items influence the price to be given;
• Requesting prior internal approvals for discounts beyond its scope;
• Deliver your proposal to the client in an unbiased manner;
• Do not comment with third parties on prices and conditions given to the customer.

If there is a need to take risks in favor of the execution of the contract/partnership, the account manager is not authorized to do so without written support, of his director.

It is necessary for the director to forward to the legal department the authorization to proceed with the signing of the term previously analyzed.

PRODOIST adopts transparent criteria that increase the degree of impartiality in the management of agenda conflicts, aiming to eliminate injustices in the asymmetry of rights and in reconciling the interests of related parties.

There should be no manipulation of the employee in order to speed up the sales process.

It is considered manipulation:

• Delaying the internal formalization of a sale in line with the customer's contract so that it can be internally recognized at another date. This posture goes against the interests interests of the client and PRODOIST, because it will generate consequent delay in the implementation of the project;
• The anticipation of internal formalization, without the complete customer information or not formalized and without all documents properly issued, signed and attached to the system. This posture generates damage for PRODOIST that will consider in its results a sale in an improper way, that will make anticipated purchases and cash mismatch and may cause damage to the image with the customer by starting the billing process and delivery to the customer of something not authorized;
• Formalization in duplicate form in whole or in part. This situation may occur if a contract or project has already been partially formalized in our systems and, at any time in the future, the same object is formalized again.

The employees will maintain total secrecy about confidential information to which they have access as a result of exercising their function, and the disclosure of any such information to unauthorized persons or to those who may use it improperly is totally forbidden.

When the employee has access to so-called "confidential information", as established in the Information Classification Policy, he must abstain from disclosing it or use it for his own benefit or for the benefit of others.

"Confidential information" means information of a materially relevant and confidential nature, the undue use or disclosure of which may, among other consequences influence the market price.

Personal matters and client business will be treated with the strictest confidentiality, not to be disclosed to any other Company or person, internal or external, without prior authorization.

When several manufacturers are together with PRODOIST in the same process, the information from one should not be passed on to the other;

• Violation of PRODOIST's policy
• Loss of sales recognition
• Loss of reward for the sale
• Financial compensation for losses arising
• Formalization of Warning
• Loss of metric-based bonus

The legal department analyzes and forwards all applicable considerations, raising illegalities, suggesting changes, and also highlighting important points.

The analysis passed by the legal department should be internal and cautious.

The consideration performed by the legal department requires time to read and analyze all the clauses and terms thoroughly.

The minimum time required is 48 working hours, considering that the legal team serves all of PRODOIST's units and is also involved in external activities.

• Sales formalizations without respective validations;
• Change of the selling trend;
• Formalization setback needs.

Each and every process must follow the legal processes of public administration without infringing the points listed in the law;

It is not forbidden to provide information for the Public Administration to generate the terms of reference and consequently the calls for tender, however, it is necessary to provide the information in a way that is justified to the object of the term of reference/edital. The employees of the sales area must know intimately our competencies (legal/fiscal and financial, technical and commercial) to justify in a correct way, and mainly, understand what kind of business/object the customer wants to hire. The objective here is besides ensuring the legal part, to minimize as much as possible the rework or surprises at the time of participation, and on the other hand, to maximize profits and customer satisfaction.

Any and all information that could characterize or appear to be some kind of offense to the public process must be treated in an exemplary manner, i.e., we don't do it. Examples: combine prices, cover proposals, payment for intermediation, etc. Any such fact must be immediately communicated to the board of directors.

Any and all matters relating to the subject should never be dealt with by telephone or messages or electronic means of any kind, as per the Term of Awareness and responsibility;

The guarantee of the business is supported by our legal/tax and financial, technical and commercial competence. of our work, always looking at the legal part and the object to be contracted by the Government;

No gift or gratuity may under any circumstances be given in exchange for inappropriate favorable treatment of the public employee, seeking any benefit for PRODOIST.

It is not permitted to offer meals, travel or entertainment to public officials to improperly influence or compensate an official act or decision, as actual or intended compensation for any benefit to the company.

To ensure compliance policy:

• Understanding Politics;
• Recognize red alerts;
• Execute the process actions with caution and attention.

Last updated on 02/09/2021 08:29:28.